Example of CSM Calculation at Initial Recognition for Profitable Contracts, Table 3. These estimates would need to be discussed and agreed with auditors and a company should be aware that if an estimate is in breach of the requirements of the FRA (i.e. Alternatively, more exotic solutions may exist that rely on interest rate swaps. The entity now needs to decide how to reflect this experience in its determination of coverage units. It considers two possible options: (a) Update its view of future coverage units from year 3 onwards to reflect the actual experience but not to update its view of the coverage units in year 2. When reporting new business profitability under SII, in general, most companies include the investment management expenses in future cash flows under SII. The Standard does not specify how to estimate the quantity of benefits under various types of contracts. Considerations of this nature would enable the volatility of the CSM with regards to both economic and operating variances to be understood. the balance that represents unearned profits ought to be updated to reflect these latest facts and circumstances. The question to now consider is this: does the risk mitigation option eliminate the potential for any mismatches to arise? At subsequent measurement, consistent with the systematic reversal of the LC, the entity will also need to systematically reverse the loss-recovery component balance over the lifetime of the group of reinsurance contracts held such that there is a zero loss-recovery component by the end of the coverage period. 22 On a retrospective basis, with-profits policies valued under the VFA would likely gradually end up having their CSM collapse into LC to reflect the dual negative impacts of continuously decreasing interest rates and generally improving annuitant longevity. if applying Fair Value Approach), or simplifications to avoid its need may be justifiable. An entity should consider the cost/benefit trade-off associated with the granularity of groups. Based on these cash flows, one can generate the following LC run-off patterns as well as an extract of the P&L entries relating to these movements. However, for many contracts outside of the UK, this requirement cannot be met. However, it is less clear what other financial assumptions are locked in. The underlying insurance contract assumes mortality follows 65% AXC00 mortality tables. OCI disaggregation; presentation of the RA in the P&L; treatment of accounting estimates made in previous reporting periods, etc.). If the firm believes the mortality table used for the underlying insurance contracts is the best estimate of the future mortality experience for this block of business, these same rates should be taken as a base for determining reinsurance recovery cash flows under the reinsurance treaty. There are often separate views of capital companies hold based on their own economic capital models. 1 The mere existence of management discretion to vary the amounts paid to policyholders does not automatically result in VFA ineligibility. We do this because the quality of implementation and application of the Standards affects the benefits that investors receive from having a single set of global standards. However, entities are required to provide IFRS 17 comparative financial statements as of the beginning of the period immediately preceding the date of initial application. When it comes to the GMM, the Standard is explicit in requiring the use of locked-in discount rates for subsequent adjustments to the CSM (see paragraph B96(b)). The IFRS Foundation is a not-for-profit, public interest organisation established to develop high-quality, understandable, enforceable and globally accepted accounting and sustainability disclosure standards. Example of Options when Determining Coverage Units. Then, there is a discussion about the purpose of systematically reversing LC. On no account may any part of this publication be reproduced without the written permission of the Institute and Faculty of Actuaries. Consequently, the interest unwinds will be on CSM at the start of the period after adjusting for the impact of change in FCF. Any excess left behind is used to establish a CSM which will then be recognised over the lifetime of the group of contracts (as per the usual requirements). Conversely, companies may prefer the MRA for transition because they reason that: A higher CSM at transition acts to smoothen out the emergence of future profits and minimise future earnings volatility (as much as possible) as it can absorb large basis updates and other experience variances that relate to future service. Whilst the interpretation arguably does not represent the economics of reinsurance notice periods, it offers opportunities for insurers to explore that may help mitigate some of the challenges arising if the future new business is included in the reinsurance contract boundary. This item consequently attempts to ensure that such cash flows are not missed from the determination of the CSM. Experience variances that are related to the current or past periods will be recorded in the income statement. Other insurers recognise profit over the duration of the insurance contract on the basis of the passage of time. (IFRS 17 Effects Analysis, page 33). As above, lets consider whether there is a contract boundary at the point where the vested annuities are bought out by the non-profit fund of the same entity which owns the WP fund (i.e. demographic basis updates, implies that such updates will (to the extent that a CSM can absorb them) have a net-zero impact on the LRC, and hence IFRS 17 equity. Table 4. Contracts without direct participating features. Due to the nature of the WP business, additional considerations need to be made when determining the level of aggregation. As a standard that is still very much in its infancy, and for which wider consensus on topics is yet to be achieved, this paper aims to provide readers with a deeper understanding of the issues and opportunities that accompany it. This section considers a specific issue that arises when determining the CSM for insurance contracts that vary with changes in underlying items, but that fail one or more of the VFA eligibility criteria. where premium reviews are not possible such as guaranteed premiums for individual protection policies). The insurer that writes this contract expects to make a profit: Recognising all this expected profit upfront creates a large disconnect with the fact that insurance service is likely to be provided over several years to come. In the first case where the impact is taken at the start of period, the future service includes the current reporting period whereas in the second case, the future service comprises strictly the service provided after the end of reporting period. policy B guarantee of 1%) can be used to meet the minimum guarantee of policy A. This stress could result in the following changes to cash flows: Increased claims volumes during the stressed period since incurred claims reflect current service, this variance will go through P&L immediately. See Terms of Use for more information. A simple example will help answer these questions. "useRatesEcommerce": false, When this happens, there is an immediate and capitalised impact on the P&L and RoE irrespective of whether the items are favourable (i.e. Note, considerations applicable to the PAA have not been included as there is no CSM calculable. From this point of view, the practical assumption is necessary. In the context of IFRS 17s level of aggregation requirements, reinsurance contracts issued are treated in the same way as insurance contracts issued (refer to paragraphs 3 and 4 of IFRS 17), but different requirements apply to reinsurance contracts held. This means that the reinsurance of VFA business needs to be measured through the GMM a case of a mismatch in measurement models. For the gross unit of account, the company will only recognise contracts as and when it actually writes this business. Note that this question is relevant to, and recommended to be read in conjunction with, the discussion in section 4.7.6. the need for a clearly identified pool to be contractually specified) is a crucial aspect of the eligibility requirements: In the UK, in the case of UL insurance or WP contracts, contractual linkage could exist by way of policy terms or PPFM, respectively. The underlying term assurance group of contracts has a risk-free discount rates curve at initial recognition. In some instances, a single complex reinsurance programme may be structured through a combination of basic reinsurance arrangements. Note again that the issue at hand here relates to the contract boundary for the future new business to be covered under the reinsurance contract this will be different to the contract boundary of the cashflows for the three contracts that are already written and covered by this reinsurance agreement (and in this case, the contract boundaries between reinsurance held and the underlying contracts need to be consistent). The insurer does quarterly reporting. This helps guide our content strategy to provide better, more informative content for our users. Alternatively, an entity may choose to apply permitted modifications to the GMM with respect to discretionary participating features described in this section. However, weighted average rates may be more suitable for periods with volatile interest rates and new business volumes, but maybe operationally difficult to calculate and track. This requires companies to find sufficient credible data (either externally or internally) and qualitative arguments to support the FV of liabilities that they calculate. This section discusses the determination of the date at which a group of new contracts should be initially recognised. If a group of contracts is or becomes loss-making, an entity recognises the loss immediately; presents separately insurance revenue (that excludes the receipt of any investment component), insurance service expenses (that excludes the repayment of any investment components) and insurance finance income or expenses; and. Separating policies in this way could give rise to data and modelling challenges. ). it is a standard non-profit annuity. Please enable JavaScript to view the site. Whether the new contract falls into a new group will depend on whether it falls into a new cohort year or not. There are two key points to consider, (a) what is the variability of the value of the pay out to customers if the guarantees are in the money and (b) how substantial should be interpreted when the pay out to customers in only based on the underlying for a proportion of the term of the contract. Only prospective financial risks are locked in, i.e. Example of Cash Flows for Two Underlying Contracts and a Reinsurance Contract held, Example of Profit and Loss Entries Based on Three Methods of Amortisation for the Loss-Recovery Component, Example of Loss-Recovery Component Balances Based on Three Methods of Amortisation. For this reason, the paper has had to be necessarily restricted to the CSM in its scope. In this respect, potential future interest rate volatility in conjunction with changes in fulfilment cash flows may result in an increased volatility of the income statement (an issue that has generated some concerns within the industry). If partial underwriting is done (e.g. The long-term nature of life insurance contracts means that the entitys estimates about the future can change as experience emerges. A broader view of the level of aggregation considerations is covered in section 3.2. Details of this asset fall outside the scope of this paper and consequently are not discussed any further. Further, portfolios are then subdivided into groups no more than 1 year apart according to paragraph 22 (excluding existing business at Transition) and by profitability levels (paragraph 16). However, for the reinsurance unit of account, the company will need to recognise estimated cash flows for the 6 contracts it expects under the quota share in this quarter; the PVFCF on the balance sheet will be 600 and the CSM will be 600 giving a reinsurance LRC of 0 as well. The International Financial Reporting Standards Foundation is a not-for-profit corporation incorporated in the State of Delaware, United States of America, with the Delaware Division of Companies (file no: 3353113), and is registered as an overseas company in England and Wales (reg no: FC023235). This explains why companies will need to spend immense amounts of effort to interpret these requirements the methodologies they commit themselves to will have significant operational and financial implications. Insurance contracts often contain a combination of different insurance benefits that vary by the amounts or types of insurance benefits payable depending on the insured event. (c) r2 is included in the group of reinsurance contracts held that are referred to as R2023. GMM and VFA. The interpretation of (b) is relatively clear, particularly given the clarification in paragraph 26 that, where there is no contractual due date, the first payment is deemed to be due when it is received. This does not make sense. (b) The 3-month notice period implies a contract boundary that includes future new business up to and including 30 March 2023. One important exception relating to Principle 5 concerns an issue relating to the interaction between gross underlying business and corresponding reinsurance held. This question is considered against two criteria: volatility and sustainability. Principle 1: When an insurer writes profitable business, it must not be allowed to recognise the expected profits for that business immediately and instead must spread those profits over time (based on paragraph 38). IFRS 17 treatment of reinsurance contracts held on initial recognition of onerous groups of underlying contracts. Other cookies are optional. The higher the percentage of onerous business (proportionally) ceded to reinsurers, or the larger the LC for the new business recognised, the larger the loss-recovery component that will be established and consequently the larger the negative contribution from reinsurance to future P&L. Either approach would need to be justified. Where an assumption about inflation is based on the entitys expectation of specific price changes this is not a financial risk. Even if a new metric is introduced, there may be an expectation from management, for the first few years, that a reconciliation is shown between the old metric (using SII VNB) and the new one (using IFRS 17 CSM). 15. Instead, an entity is expected to apply expert judgement when determining coverage units considering its specific facts and circumstances and to disclose the approach applied. Under the risk mitigation option, the company will recognise + 5 and 5 in the P&L immediately for (1) for each of gross and reinsurance. One potential intermediate and pragmatic approach could see the entity not discounting the quantity of benefits in the coverage unit calculation but concurrently not modelling the annual contractual inflationary increases solely for the purposes of determining the coverage unit (i.e. This meets the requirement of paragraph 52. For in-force business at transition, IFRS 17 provides flexibility to group contracts issued more than 12 months apart. The CSM at the end of the reporting period is consequently the net result of each of the elements above. If that is all that is the case, why does IFRS 17 have so much to say about LC? Consequently, the amount allocated to the LC due to changes in the discount rate is = 374 4.57% = 17. Paragraph 87 states that changes in the value of the insurance contract due to changes in the time value of money and financial risk should be captured within insurance finance income or expense. The liability for remaining coverage comprises the FCF related to future services and the CSM of the group at that date. deduct the change in RA caused by RA release before the transition and estimate this amount by reference to release of risk for similar insurance contracts issued on transition. The calculation required to determine the FV CSM or loss component. However, this seems too simple; in fact, this only works when the underlying contracts are 100% reinsured. The total reported insurance service expense is 100 and is now exactly equal to the actual claims and expenses incurred over the lifetime of the contract. At that point, it assesses the treaty and determines that it should recognise a reinsurance contract (referred to as r1) on the IFRS 17 balance sheet as follows: (a) Initial recognition date of 31 December 2022. Initially, a simple example will be considered to demonstrate the principle of including future new business in the reinsurance contract boundary. In analysing the ability to reassess the risks, both at individual and portfolio level, it is worth noting the February 2018 Transition Research Group (TRG) discussionFootnote The reinsurance CSM reduces from 600 to 490 (a reduction of 110). Section 2 covers the basics of the CSM. $${2 \over 5}$$ Whilst going over and above the IFRS 17 requirements is technically and operationally more demanding, and arguably leads to a more accurate reflection of accounts, the costs of doing so may not always exceed the benefits. There is room for interpretation and the assessment will require significant judgement. Steps for Calculating the CSM at Initial Recognition. Contracts will need to be moved into new CSM groups at the review point. However, there is a wider debate whether this requirement also holds in respect of the LC. As highlighted in the preceding section, there are different methods that firms could adopt in calculating the FV CSM (e.g. IFRS 17 criteria for determining when a substantive obligation ends: It systematically reverses the LC as quickly as possible and consequently increases the likelihood of a CSM being established (subject, of course, to future favourable assumption updates or experience variances relating to future service). IFRS 17 Insurance Contracts is a new accounting standard that entities are expected to apply for reporting periods beginning on or after 1 January 2023 (though earlier application is permitted). In this case, locked-in interest rates that have been used since the contract inception for tracking the LC will continue to be used for the CSM. proportion of contracts that lapse at the review point. The future date where the insuranceundertaking has a unilateral right to reject premiums payable under the contract; (c) This meets the requirements of paragraph 49. This section explores some of these differences, as well as identifying product features, which may require judgement to determine the appropriate contract boundary under IFRS 17. For ease, these have been collated in Table40. Should a company apply the MRA or the FVA? Figure 6. In either instance, the revised cash flows (after revising the mortality assumptions) would be discounted at rates based on initial recognition. they are effectively underlying items of the WP fund. Figure 7. However, as paragraph BC282 (May 2017) notes, IFRS 17 does not specify whether an entity should consider the time value of money in determining that equal allocation and consequently does not specify whether that equal allocation should reflect the timing of the expected provision of the coverage units. Indeed, such matters have been left by the IASB to be a matter of judgement by an entity. An IASB paperFootnote Companies should investigate the practicability, relative costs and benefits of the two approaches. How should these be accounted for? Table 18. In some stochastic scenarios, payouts will clearly vary with the changes in the fair value of the underlying items because the return on the investment fund exceeds the guaranteed return. The general model is defined such that at initial recognition an entity shall measure a group of contracts at the total of (a) the amount of fulfilment cash flows (FCF), which comprise probability-weighted estimates of future cash flows, an adjustment to reflect the time value of money (TVM) and the financial risks associated with those future cash flows and a risk adjustment for non-financial risk; and (b) the contractual service margin (CSM). It is important to note that NDIC must not be included as part of the cash outflows (as they do not form part of revenue) which means that the computations will become much more difficult. IFRS 17 does not provide detailed requirements about how an entity determines the relative weightings of the benefits provided by the services in an insurance contract or for a group of insurance contracts. Either way, the result is a depression of subsequent periods profits (or accentuation of losses) and consequently an understatement of the insurers future profit profile. Many other examples exist that would satisfy the consistency requirement. Example of PVFCF, CSM and LRC profiles for gross and reinsurance units of account assuming future new business will only be recognised as and when it is recognised for the gross unit of account. Paragraph B108 addresses contracts that offer minimum investment-return guarantees to policyholders (e.g. The IASB issued a discussion paper in 2007 and the first exposure draft "ED/2010/8 Insurance Contracts" in July 2010. A CSM is only calculated under the GMM and VFA; there is no concept of a CSM under the PAA. locking in all financial assumptions and not just the discount rates in order to capture the appropriate impact of the change in longevity assumptions. Table 19. This section sets out: An overview of the transition requirements under IFRS 17. Given that the Standard explicitly allows either approach (which could result in a significantly materially disparate profile of releases of CSM over time as shown above) and that paragraph BC282 (May 2017) ultimately considers this item a matter of judgement to be made by an entity, some practitioners may seek to follow an intermediate approach. Why do certain items need to be systematically allocated to the LC? whether or not the coverage units should be discounted). The requirement, that in order to apply the insurance standard to investment contracts with DPF, an entity has to also issue insurance contracts. An extreme outcome could be for this to become a constraint on the dividend-paying capacity of the company. 68.6 = 70 (amount released in revenue) 98% (year 2 SAR). At the same time, current discount rates will be used to calculate the PVFCF shown on the balance sheet. Table 7. The loss component determines the amounts that are presented in profit or loss as reversals of losses on onerous groups and are consequently excluded from the determination of insurance revenue.. Changes in RA will need to be considered as to whether any part of this change relates to future service and is consequently relevant in adjusting the CSM. 23 See February 2020 IASB AP2A Contractual service margin attributable to investment services. The consistency requirement will be applicable to the assumptions used to derive the best estimate cash flow projections and discount rates for measuring reinsurance contracts on initial recognition as set out in paragraphs 3236 through the reference from paragraph 63. deduct the cash outflows that occurred before the transition and that did not vary based on underlying items (e.g. Example of Profit and Loss Entries Based on Three Methods of Amortisation for the Loss-Recovery Component, Table 33. In reality, it turns out that only 1 contract is written per month. To assess this the VFA requirements in paragraph B101 apply. Like all financial ratios, a meaningful comparison of the RoE reported by different companies shall consequently require a careful understanding of how the RoE was arrived at to allow for such features. These must be considered when adjusting the CSM. The CSM is set-up as a component of the balance sheet and is recognised in the P&L account as and when the insurance contract services are provided. This example uses the same contract from Example 4.6. For this reason, the conclusion is that it is unlikely for there to be readily usable prices to identify the FV of a liability simply by looking towards the market and work will be required to consider the information available before it is used. Again, the answer will depend on the specifics of the product, so instead of giving an explicit answer, this section lays out some of the points to consider in this scenario. Given the CSM is floored at 0 (for direct underlying contracts), various sensitivities would have a maximum stress parameter tolerance before the number of groups of contracts became onerous. For example, policy administration systems do not always have an embedded link to pricing models consequently existing processes may not be able to immediately identify when a loss-making policy has been written. The significant benefit to users of financial statements outweighs the additional complexity to accounting systems the annual cohort requirement introduces. A number of possibilities have been considered by the industry: Is the WP element a distinct investment component? Example 4.3: A 5-year endowment policy with a sum assured of 100,000 payable on death. https://www.actuaries.org.sg/sites/default/files/2020-09/SAS%2017WG%20%E2%80%93%20Coverage%20Unit%20v1.0.pdf. extent that the Estate absorbs risks and hence losses. Both approaches would be allowed under IFRS 17 despite resulting in two possible extremes as shown in the graph below: the potential for excessive profit deferral when not allowing for time value and the potential for undue profit acceleration when allowing for time value. This section describes specific implications that the CSM and LC are expected to have on this ratio. Some examples of when this may occur are discussed below. This change will need to be carefully managed internally and externally. https://www.icaew.com/-/media/corporate/files/technical/financial-services/ifrs17-and-iasb/coverage-period-and-csm-release-for-deferred-annuities.ashx?la=en. Whether the second and third criteria are met depends upon whether the entity performs any investment activity and that this activity enhances the amount that the policyholder has a right to withdraw during the deferment period (the investment activity need not generate a positive investment return). per policy maintenance expenses or fixed death benefits. The coverage period and quantity of benefits are separate concepts, which will be considered in further detail below: The coverage period should take into account the actual term of the policy, adjusted to reflect expected lapses, claims and the impact of any other expected decrements over time.
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